last antecedent doctrine (North Carolina) · Go Syfert
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last antecedent doctrine in North Carolina

10 North Carolina opinions name it 3 courts 1990–2026 3 in the last five years

The cases below were cited by North Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
HCA Crossroads Residential Centers, Inc. v. North Carolina Department of Human Resourcesgreen
nc · 1990 · cited in 8 North Carolina opinions naming this issue, 1993–2026
2 sentences

2026Res., Div. of Facility Servs., Certificate of Need Section, 327 N.C. 573, 578 , 398 S.E.2d 466, 469 (1990) (applying the doctrine of the last antecedent).

2026Res., Div. of Facility Servs., Certificate of Need Section, 327 N.C. 573, 578 , 398 S.E.2d 466, 469 (1990) (applying the doctrine of the last antecedent).

68
Wilkie v. City of Boiling Spring Lakesgreen
nc · 2018 · cited in 2 North Carolina opinions naming this issue, 2026–2026
2 sentences

2026In Philip Morris, our Supreme Court applied the “doctrine of the last antecedent,” stating, “relative and qualifying words, phrases, and clauses ordinarily are to be applied to the word or phrase immediately preceding rather than extending to or including others more remote.” 386 N.C. at 757, 909 S.E.2d at 204 (citation modified); see also Wilkie v. City of Boiling Spring Lakes, 370 N.C. 540 , 548–49, 809 S.E.2d 853, 859 (2018) (applying the doctrine of the last antecedent); HCA Crossroads Residential Ctrs., Inc. v. N.C.

2026In Philip Morris, our Supreme Court applied the “doctrine of the last antecedent,” stating, “relative and qualifying words, phrases, and clauses ordinarily are to be applied to the word or phrase immediately preceding rather than extending to or including others more remote.” 386 N.C. at 757, 909 S.E.2d at 204 (citation modified); see also Wilkie v. City of Boiling Spring Lakes, 370 N.C. 540 , 548–49, 809 S.E.2d 853, 859 (2018) (applying the doctrine of the last antecedent); HCA Crossroads Residential Ctrs., Inc. v. N.C.

22
O & M INDUSTRIES v. Smith Engineering Co.green
nc · 2006 · cited in 1 North Carolina opinions naming this issue, 2018–2018
2 sentences

2018In addition, it seems to us that a decision to provide a claimant whose property has been taken for a public purpose with a statutory *860 inverse condemnation remedy while depriving a claimant who has suffered the same injury for a non-public purpose of the right to utilize that statutory remedy seems inconsistent with the likely legislative intent. "[W]hen the Act is considered as a whole in the light of the evils sought to be eliminated, the remedies intended to be applied, and the objective to be attained," a decision to construe N.C.G.S. § 40A-51 so as to limit plaintiffs' statutory inver

2018In addition, it seems to us that a decision to provide a claimant whose property has been taken for a public purpose with a statutory *860 inverse condemnation remedy while depriving a claimant who has suffered the same injury for a non-public purpose of the right to utilize that statutory remedy seems inconsistent with the likely legislative intent. "[W]hen the Act is considered as a whole in the light of the evils sought to be eliminated, the remedies intended to be applied, and the objective to be attained," a decision to construe N.C.G.S. § 40A-51 so as to limit plaintiffs' statutory inver

11
State v. Cloningergreen
ncctapp · 1986 · cited in 1 North Carolina opinions naming this issue, 1990–1990
2 sentences

1990Statutes § 334 (1953); see also 73 Am.Jur.2d Statutes § 230 (1974) ("In construing statutes, qualifying words, phrases, and clauses are ordinarily confined to the last antecedent, or to the words and phrases immediately preceding"); cf. State v. Cloninger, 83 N.C.App. 529, 531 , 350 S.E.2d 895, 897 (1986) (applying but not announcing the doctrine of last antecedent).

1990Statutes § 334 (1953); see also 73 Am.Jur.2d Statutes § 230 (1974) ("In construing statutes, qualifying words, phrases, and clauses are ordinarily confined to the last antecedent, or to the words and phrases immediately preceding"); cf. State v. Cloninger, 83 N.C.App. 529, 531 , 350 S.E.2d 895, 897 (1986) (applying but not announcing the doctrine of last antecedent).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in North Carolina. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Puckett v. Sellars green
nc · 1952
2 sentences

2018In addition, it seems to us that a decision to provide a claimant whose property has been taken for a public purpose with a statutory *860 inverse condemnation remedy while depriving a claimant who has suffered the same injury for a non-public purpose of the right to utilize that statutory remedy seems inconsistent with the likely legislative intent. "[W]hen the Act is considered as a whole in the light of the evils sought to be eliminated, the remedies intended to be applied, and the objective to be attained," a decision to construe N.C.G.S. § 40A-51 so as to limit plaintiffs' statutory inver

2018In addition, it seems to us that a decision to provide a claimant whose property has been taken for a public purpose with a statutory *860 inverse condemnation remedy while depriving a claimant who has suffered the same injury for a non-public purpose of the right to utilize that statutory remedy seems inconsistent with the likely legislative intent. "[W]hen the Act is considered as a whole in the light of the evils sought to be eliminated, the remedies intended to be applied, and the objective to be attained," a decision to construe N.C.G.S. § 40A-51 so as to limit plaintiffs' statutory inver

12018–2018
Barnhart v. Thomas green
scotus · 2003
2 sentences

2012Ct. 2001) at *17–18. {75} In response, Plaintiffs stress that Judge Tennille also recognized that the doctrine of the last antecedent does not apply where “the context indicates a contrary intent . . .” Id. {76} In discussing the doctrine of the last antecedent as applied to statutory interpretation, the United States Supreme Court stated that, “[w]hile this rule is not an absolute and can assuredly be overcome by other indicia of meaning, we have said that construing a statute in accord with the rule is quite sensible as a matter of grammar.” Barnhart v. Thomas, 540 U.S. 20 , 124 S.Ct. 376 (2

2012Ct. 2001) at *17–18. {75} In response, Plaintiffs stress that Judge Tennille also recognized that the doctrine of the last antecedent does not apply where “the context indicates a contrary intent . . .” Id. {76} In discussing the doctrine of the last antecedent as applied to statutory interpretation, the United States Supreme Court stated that, “[w]hile this rule is not an absolute and can assuredly be overcome by other indicia of meaning, we have said that construing a statute in accord with the rule is quite sensible as a matter of grammar.” Barnhart v. Thomas, 540 U.S. 20 , 124 S.Ct. 376 (2

12012–2012
Marcoin, Inc. v. McDaniel green
ncctapp · 1984
1 sentence

2001Consequently, the Court does not rely solely on the doctrine of the last antecedent for its ruling, although it is logical to apply it here. {23} The Court additionally relies on two basic rules of contract construction: (1) “that a contract must be construed as a whole, considering each clause and word with reference to other provisions and giving effect to each whenever possible. . . .” and (2) “the common or normal meaning of language will be given to the words of a contract unless the circumstances show that in a particular case a special meaning should be attached to it.” Marcoin, Inc. v.

12001–2001

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 1A-1 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

WA 72 (1941–2026) IL 64 (1977–2024) TX 60 (1979–2025) CA 53 (1991–2024) MI 38 (1975–2026) FL 29 (1981–2024) OR 18 (1996–2024) MO 17 (1973–2022) AZ 16 (1984–2025) PA 15 (1974–2026) NM 11 (1996–2022) NC 10 (1990–2026) CO 10 (1989–2026) MA 9 (1940–2025) SD 8 (1990–2011) WI 7 (1915–2021) OK 7 (1994–2025) CT 7 (1996–2019) KS 6 (1989–2022) ID 5 (1994–2026) NY 5 (1931–2018) OH 5 (2011–2024) VA 5 (2004–2023) NH 4 (2010–2025) MD 4 (2014–2026) NJ 3 (2017–2021) AK 3 (1983–2010) NV 3 (2011–2015) MN 3 (2016–2019) IA 3 (2006–2016) RI 2 (1985–2013) DE 2 (2016–2021) ND 2 (2019–2023) IN 2 (2008–2016) VT 2 (2010–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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